## PLACER COUNTY

AIR POLLUTION CONTROL DISTRICT



# STAFF REPORT

RULE 2 3 8

FACTORY COATING OF FLATWOOD PANELING

PROPOSED RULE AMENDMENT S

October 14, 2010Staff Report

– Proposed Revision to Rule 2 38

October 14, 2010

Page 2

BACKGROUND

R ule 23 8

, FACTORY COATING OF FLATWOOD PANELING

, limits the volatile or ganic

compound (VOC) emissions from wood products coating operations in the Placer County Air

Pollution Control District (District) . The rule was last amended by the District on February 18

, 2004

.

The District is proposing amendments to Rule 23 8 to be co nsistent with U.S. EPA’s “Control

Techniques Guidelines for Flat Wood Paneling Coatings,” (EPA 453/R

- 06

- 004), dated September

2006, changes being made to Rule 218, ARCHITECTURAL COATINGS and Rule 23 6

, WOOD

PRODUCTS COATING OPERATIONS

, and to meet our requi rement for VOC emission

reductions for attainment of Sta te and Federal ozone standards.

This Staff Report addresses amendments that are proposed to Rule 2 3 8

.

DISCUSSION

Review of District Rule coating VOC content limits indicates they are consistent an d up to date

with the best available control practices based on review of local, State, and Federal

requirements.

Proposed amendments to the R ule , in underline/strikeout format, are shown in Attachment #1.

Specific changes to the R ule include:

Section 10 0

. General

Section 102. 1 Applicability , Geographic

. Section 102. 1 Applicability , Geographic

. The

Rule has been expanded to apply to the entire District, including the Mountain Counties

and Lake Tahoe Air Basins

. The Rule previously was limited to the Sacramento Air Basin.

Section 200. Definitions

New definitions were added for tints and stains.

Section 300. Standards

Section 301.2 The control device efficiency alternative has been changed to from 90% to

95%.

Section 303 and 304

. Work Practices

. Work practice provisions ha ve been added based

on U.S. EPA’s Control Techniques Guidelines

.

Section 500. Monitoring and Records

Section 503. Test Methods

. R eference was added to additional test methods, and minor

changes were made to the methods in th e cur rent R ule.

ANALYSIS

The following Analysis and the subsequent Findings are intended to address the requirements set

forth in the Health and Safety Code relating to adoption of a new or amended District Rule, as well as

other St ate statutes reference d herein.

1. Cost

- Effectiveness of a Control MeasureStaff Report

– Proposed Revision to Rule 2 38

October 14, 2010

Page 3

California Health & Safety Code (H&S) Section 40703 requires a District to consider and

make public “the cost

- effectiveness of a control measure”. The cost effectiveness can not

be determined since th e rule amendments will have no significant cost to comply and no

significant emission reductions.

2. Socioeconomic Impact

H&S Section 40728, in relevant part, requires the Board to consider the socioeconomic

impact of any new or amended rule if air quali ty or emission limits are significantly affected.

The expected economic impact on the flat wood paneling operati o n s , including two (2) with

District permits, is expected to be insignificant.

3. E nvironmental R eview and C ompliance

California Public Resou rces Code Section 21159 requires an environmental analysis of

the reasonably foreseeable methods of compliance should be conducted. Compliance of

the proposed rule amendment is expected to be achieved by the replacement of current

coating products with co mpliant compounds. Application of these compliant compounds

will generally result in less VOC emissions from the coating activities. Therefore, the

proposed rule amendment will reduce emissions from sources and will not cause any

significant adverse effe cts on the environment. Staff has concluded that no adverse

environmental impacts will be caused by compliance with the proposed rule amendment.

According to the above conclusion, Staff finds that the proposed rule amendment is

exempt from the California Environmental Quality Act (CEQA) because ( 1) it can be seen

with certainty that there is no possibility that the activity in question may have a significant

adverse effect on the environment (CEQA Guidelines §15061(b)(3)) and ( 2) it is as an

action by a r egulatory agency for protection of the environment (Class 8 Categorical

Exemption, CEQA Guidelines §15308).

FINDINGS

A. Necessity : The adoption of proposed amended Rule 2 3 8 satisfies the Districts objective

to reduce VOCs to achieve attainment with amb ient air standards for ozone , and meets

the District’s requirements to implement “every feasible measure” and “Best Available

Retrofit Control Technology” as required under California Health and Safety Code

Sections 40919 and 40914

.

B. Authority : California Health and Safety Code, Sections 40000, 40001, 40701, 40702,

40716 , 41010, and 41013, are provisions of law that provide the District with the authority

to adopt this proposed amended R ule.

C. Clarity : There is no indication, at this time, that the proposed amended R ule is written in

such a manner that persons affected by the R ule cannot easily understand them.

D. Consistency : The proposed amended Rule is in harmony with, and not in conflict with or

contradictory to, existing statutes, court decisions, or state or federal regulations.

E. Non

- duplication : The proposed amended Rule does not impose the same requirements

as an existing state or federal regulation.

F. Reference : All statutes, court decisions, and other provisions of law used by the District in

interpreti ng this proposed amended Rule is incorporated into this analysis and this finding

by reference.Staff Report

– Proposed Revision to Rule 2 38

October 14, 2010

Page 4

SUMMARY

Rule 2 3 8

, FACTORY COATING OF FLATWOOD PANELING , has been amended to be

consistent with the U.S. EPA’s Control Techniques Guidelines, other District r ules

, and to meet

our requirement to meet ozone ambient air quality standards

.

Attachment 1: Proposed Rule 38 6 Amendments.

### ATTACHMENT #1

Amended Rule 238, Flat Wood Paneling